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32. D died with $20,000,000 of cash assets. D's will created 4 irrevocable trusts, each of which received $5,000,000 from the estate. Trust 1 stated
32. D died with $20,000,000 of cash assets. D's will created 4 irrevocable trusts, each of which received $5,000,000 from the estate. Trust 1 stated that D's son would receive all trust income for son's life and the remainder would be distributed to a qualified charity (The FMV of the income interest was $3,500,000). Trust 2 stated that D's spouse would receive all trust income for spouse's life and the remainder would be distributed to a qualified charity (the FMV of the income interest was $1,500,000). Trust 3 stated that a qualified charity would receive $100,000 per year for 15 years and the remainder would be distributed to D's son (The FMV of the income/annuity interest was $1,000,000). Trust 4 stated that D's son would receive $100,000 per year for 15 years and the remainder would be distributed to a qualified charity (The FMV of the income/annuity interest was $1,000,000). What is D's Taxable Estate? 33. D's Aunt died leaving $1,000,000 in an irrevocable trust which would pay D income for life, and upon D's death, remainder to any of (1) D's descendants, (ii) D's spouse, or (iii) any qualified charity as D would appoint in D's will. D died when the trust value was $2,500,000. D's Will exercised the power of appointment by appointing the $2,500,000 to an irrevocable testamentary trust which paid all income to D's spouse for life, on an annual basis, remainder to a qualified charity (at the time of D's death the fair market value of the income interest was $500,000 and the fair market value of the remainder was $2,000,000). a. What, if anything, is included in D's Taxable Estate? b. How much, if anything, is D's Charitable Deduction 32. D died with $20,000,000 of cash assets. D's will created 4 irrevocable trusts, each of which received $5,000,000 from the estate. Trust 1 stated that D's son would receive all trust income for son's life and the remainder would be distributed to a qualified charity (The FMV of the income interest was $3,500,000). Trust 2 stated that D's spouse would receive all trust income for spouse's life and the remainder would be distributed to a qualified charity (the FMV of the income interest was $1,500,000). Trust 3 stated that a qualified charity would receive $100,000 per year for 15 years and the remainder would be distributed to D's son (The FMV of the income/annuity interest was $1,000,000). Trust 4 stated that D's son would receive $100,000 per year for 15 years and the remainder would be distributed to a qualified charity (The FMV of the income/annuity interest was $1,000,000). What is D's Taxable Estate? 33. D's Aunt died leaving $1,000,000 in an irrevocable trust which would pay D income for life, and upon D's death, remainder to any of (1) D's descendants, (ii) D's spouse, or (iii) any qualified charity as D would appoint in D's will. D died when the trust value was $2,500,000. D's Will exercised the power of appointment by appointing the $2,500,000 to an irrevocable testamentary trust which paid all income to D's spouse for life, on an annual basis, remainder to a qualified charity (at the time of D's death the fair market value of the income interest was $500,000 and the fair market value of the remainder was $2,000,000). a. What, if anything, is included in D's Taxable Estate? b. How much, if anything, is D's Charitable Deduction
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